Norway: Supreme Court issues rules in favor of Shell subsidiary in transfer pricing case
On 28 May 2020, the Norwegian Supreme Court issued a ruling in a transfer pricing case between the Shell group’s Norway subsidiary, A/S Norske Shell, and the Norwegian oil taxation office. A / S Norske Shell has petroleum activities on the
See MoreSpain: Cabinet approves a draft bill for digital services tax (DST)
On 18 February 2020, the Spanish Cabinet reportedly approved a draft bill for the introduction of a digital services tax (DST). A 3% DST will be applicable for large companies whose respective groups have revenue of at least EUR 750 million
See MoreAustria: Finance Ministry publishes updated information regarding DST
On 24 February 2020, the Ministry of Finance published updated information regarding the process of how to register and make payment of digital service tax
See MorePoland: Administrative Court allows expenditure on intra-group services
On 6 February 2020, Polish Administrative Court (the “Court”) issued its decision on a transfer pricing case regarding Poland vs Shared Service Center. A shared service center (SSC) in Poland both provided intra-group services to the group
See MoreCzech Republic: Government publishes final draft Bill of DST in Parliament
On 22 January 2020, the final draft Bill regarding the digital service tax (DST) was published in the Parliament. This Bill proposed to introduce a single digital tax of 7% for companies with a global revenue thresholds of EUR 750 million and
See MoreItaly enacts digital services tax
The Italian Budget Law 2020 introduces a 3% unilateral ‘Digital Services Tax (DST)’ replacing the “Web Tax” and entered into force as of 1 January 2020. The Digital Services Tax (DST) rate is 3% and applies on the revenues from digital
See MoreGermany: Federal Ministry of Finance publishes a draft law with significant changes to TP rules
On 10 December 2019, Germany published a draft law implementing EU anti-tax avoidance directive. The Draft Law includes significant changes to the German transfer pricing rules. The following proposed changes have been taken place under the
See MoreHigh Court rules that the Danish loss-making company could not deduct royalties paid to its Swiss parent
On 28 October 2019, the Eastern High Court of Denmark published a case (Denmark vs Adecco; Case No SKM2019.537.OLR of 4 July 2019) decision and agreed with the tax authority that a Danish loss-making company could not deduct royalties paid to its
See MoreTurkey: Parliament passes laws on tax regulation
On 21 November 2019, the Turkish Parliament approved laws on tax regulation which includes new taxes, namely digital services tax (DST), valuable house tax and accommodation tax. The law increases tax rate from 30% to 40% for people earning
See MoreUS: Court of Appeals denies the petition for rehearing of Altera Corp. v. Commissioner
On 12 November 2019, the Ninth Circuit denied the taxpayer’s motion for rehearing en banc through issued an order. The order means that the Ninth Circuit will not reconsider its June 7, 2019 decision upholding the validity of the SBC rule in Reg.
See MoreFinland: Ministry of Finance issues a proposal to implement a corporate exit tax
On 7 November 2019, the Finnish Ministry of Finance published a proposal to introduce a corporate exit tax, largely based on the EU's Anti-Tax Avoidance Directive. The purpose of the EU exit tax is to prevent companies from avoiding tax on gains on
See MoreItaly publishes Law 117 to implement EU Directives
On 4 October 2019, Italy has published Law No. 117 in the Official Gazette, approving the legislative decrees for the implementation of several EU Directives. The Directives will be consulted on by parliament but do not require further approval
See MoreRussia enacts legislative changes on Transfer Pricing and MAP
On 29 September 2019, the Russian Government signed a Law no. 325-FZ (Amendments to the Tax Code of the Russian Federation) and published in the Official Gazette. The main amendments relating to transfer pricing are as
See MoreBelgium approves draft law to transpose EU directive on cross-border arrangements
On 11 October 2019, the Belgian Council of Ministers approved a draft law to transpose EU Directive 2018-822 of 25 May 2018 on reportable cross-border tax planning arrangements. The Directive includes measures to require the reporting of
See MoreBrazil: Federal Revenue approves Private Ruling 276/2019
On 2 October 2019, the Brazilian tax authorities released a private ruling PLR 276/2019 on tax treatment of cross-border cost sharing arrangements. The ruling provides a consultation solution that was requested by an entity whose direct parent
See MoreArgentina: AFIP announces draft transfer pricing guidance for public comments
On 2 October 2019, tax authority of Argentina (AFIP) announced a public consultation and posted on the AFIP website a draft resolution concerning transfer pricing compliance procedures. It would replace the existing transfer pricing rules in
See MoreItaly: New resolution amends patent box regime
The Italian Revenue Agency published Resolution No, 81/E of 9 September 2019 in the official gazette to amend the patent box regime made by Law Decree No. 34 of 30 April 2019, which entered into force on 1 May 2019. The updates
See MoreUS: Court of Appeals approves Tax Court’s decision in Transfer Pricing case
On 16 August 2019, the U.S. Court of Appeals for the Ninth Circuit in the case of: Amazon.com, Inc. v. Commissioner, 148 T.C. 108 (2017) issued a decision in favor of Amazon concerning the regulatory definition of intangible assets and the
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